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[Cites 18, Cited by 0]

Central Information Commission

Rudrapriyo Ray (Axis Bank) vs Reserve Bank Of India on 10 August, 2022

Author: Neeraj Kumar Gupta

Bench: Neeraj Kumar Gupta

                          के   ीय सूचना आयोग
                   Central Information Commission
                      बाबा गंगनाथ माग,मुिनरका
                    Baba Gangnath Marg, Munirka
                    नई द ली, New Delhi - 110067

ि तीय अपील सं या/Second Appeal Nos.        CIC/RBIND/A/2021/130761,
                                           CIC/RBIND/A/2021/616628,
                                           CIC/RBIND/A/2018/170550,
                                           CIC/RBIND/A/2019/149848,
                                           CIC/RBIND/A/2020/110642,
                                           CIC/RBIND/A/2020/108661,
                                           CIC/RBIND/A/2021/631037,
                                           CIC/RBIND/A/2021/101496,
                                           CIC/RBIND/A/2021/600195,
                                           CIC/RBIND/A/2021/614140,
                                           CIC/RBIND/A/2021/117309,
                                           CIC/RBIND/A/2021/602631,
                                           CIC/RBIND/A/2021/616093,
                                           CIC/RBIND/A/2020/105506
                                                    (Total 14 cases)
Mr. Jitender Gupta                                ... अपीलकता/Appellants
Ms. Samita Sandhane
Mr. A. Rajendran
Mr. Dinesh Harchandani
Mr. Pradeep Kumar C Nair
Mr. Navin Trivedi
Mr. Sunil Kumar Jha
Mr. CP Srivastava
Mr. S K Patnaik
Mr. Bipin Chandra Khanna
Mr. Rudrapriyo Ray

                                VERSUS
                                 बनाम
CPIO                                              ... ितवादी/Respondents
Reserve Bank of India
Department of Supervision, Centre-1
World Trade Centre, Cuffe Parade, Colaba
Mumbai-400005



                                                                Page 1 of 16
 CPIO
Reserve Bank of India
Department of Co-operative Banking
Supervision, Central Office, C-7, 1st Floor,
Bandra Kurla Complex, Bandra East,
Mumbai-400051


                                   ORDER

1. The details of information sought by the appellant in all the above 15 RTI applications and the date of reply on which the reply was given by the CPIO in each of those applications is enumerated in Annexure-'A' as enclosed along with this order.

2. Being aggrieved with the response given by the respondent, the appellant banks/financial institution (as mentioned above) filed 15 second appeals under Section 19(3) of the RTI Act before the Commission requesting to set-aside the order passed by the CPIO/FAA.

3. The following matters were earlier listed before the Commission in file nos. CIC/RBIND/A/2021/130761 dated 30.09.2021, CIC/RBIND/A/2021/616628 dated 04.06.2021, CIC/RBIND/A/2018/170550 dated 08.12.2020 & 22.04.2022, CIC/RBIND/A/2019/149848 dated 26.04.2022, CIC/RBIND/A/2020/110642, CIC/RBIND/A/2020/108661 dated 21.03.2022 & 10.06.2022, CIC/RBIND/A/2021/631037 dated 30.07.2021, CIC/RBIND/A/2021/600195 dated 04.06.2021, CIC/RBIND/A/2021/614140 dated 04.06.2021, CIC/RBIND/A/2021/117309 dated 04.06.2021, CIC/RBIND/A/2021/602631 dated 04.06.2021, CIC/RBIND/A/2021/616093 dated 04.06.2021 & CIC/RBIND/A/2020/105506 dated 21.03.2022. The matters are listed today for further hearing.

Hearing:

4. Shri Narender Chopra (Accountant) along with Shri Naveen Gaur (Clerk) (Representative of Delhi Nagrik Sehkari Bank Ltd.), Adv Dharav Shah and Adv.

Dhawal Desai (Counsels for Lakshmi Vilas Bank Ltd. & Axis Bank), Adv. Mukund P. Unny (Counsel for Yes Bank) attended the hearing in person. Adv. Parshotam Khanchandani (Counsel for Nav Jeevan Co-operative Bank Ltd.), Aayesh Gandhi (Counsel for HDFC Bank), Ms. Shreeja Rani, Chief Manager along with Shri Sandeep Ghoshal, DGM (Representative of Indian Bank), Shri Praveen Kumar, CPIO/AGM (Representative of UCO Bank), Shri Jayadheesh (Representative of Union Bank of India), Shri A.K. Mishra (Representative of Bank of Baroda) attended the hearing through video conferencing. The Page 2 of 16 respondent, Shri Vinod Kumar, Representative of CPIO/ DGM along with Ms. Rajlaxmi Sethi, AGM and Ms. Ritika (Legal Officer) attended the hearing through video-conferencing. Shri Archan Misra (Original Applicant), Adv. S.K. Gauda (on behalf of Original Applicant Shri Jaidev S. Kalyani) attended the hearing through video-conferencing. The other remaining original RTI applicants were not present in the hearing despite notice.

5. The written submissions of the parties are taken on record.

6. The parties are agreed for adjudication of above mentioned cases together, as the subject matter is similar in nature.

7. The appellants, Delhi Nagrik Sehkari Bank Ltd. and Nav Jeevan Cooperative Bank Ltd. submitted that the information sought by the original RTI applicant regarding Inspection Report(s) for the years 2017 to 2021 are not the information/ document which can be provided under the provisions of RTI Act, 2005. It is a privilege document and without written permission from RBI, the same cannot be provided to any Third party. The appellant further submitted that the respondent has dismissed the First Appeal on merits and without providing opportunity of personal hearing to the appellant. The Appellant strongly believes that Respondent(s) have arbitrarily and without considering the relevant laws allowed the application of the applicant. The appellant bank further submitted that the respondent did not consider the materials on record as referred in relevant paras of the First Appeal which clearly shows the lackadaisical approach of Respondent(s)in implementing the RTI Act.

8. The appellant, UCO Bank submitted that providing the inspection report of the Bank might hamper the Bank's competitive position and would cause prejudice to Bank's commercial interest, hence, the disclosure thereof was exempted under section 8 (1) (d) of the RTI Act. The appellant bank further contended that RAR and Inspection Report contained third party/customer information, held by the bank in fiduciary capacity and disclosure of information to the RTI applicant might jeopardize the banker-customer relation and might amount to infringement of their fiduciary relation hence the same was exempted under section 8 (1) (e) & (j) of the RTI Act. Besides, the appellant bank vehemently argued that the CPIO of RBI while conveying his intention to disclosure the information, had failed to explain as to how the information sought would have served the larger public interest.

9. The appellant, Laxmi Vilas Bank Ltd. submitted that the order of the FAA and CPIO are erroneous in law, which resulted in miscarriage of justice. The Learned FAA and CPIO has failed to analyze the nature of the case and facts involved in the case and ill motive of the applicant. The Learned FAA & CPIO failed to note that M/s. Strategic Credit Capital Pvt. Ltd, M/s. Participation Page 3 of 16 Finance and Holdings (India) and M/s Loancore services solutions Pvt. Ltd have filed cases before High court, Delhi and District court of Delhi, Patiala House for non-disbursement of the sanctioned credit facility. The said case is being contested by the bank and the same is pending for adjudication. Meanwhile, appellant has received various threatening mails from various persons including from the applicant related company i.e. M/s'Emppel'. The various communications received from them clearly establish the ill motives of the applicant to put the bank under pressure to extract huge money. Hence, bank has lodged criminal complaint against them with the commissioner of police, Chennai and also private complaint before the Metropolitan Magistrate court, Egmore, Chennai. The cases filed against the bank and filed by the bank are subjudice in the respective court.

10. The appellant, HDFC Bank Ltd. submitted that the CPIO without appreciating the contentions / objections raised by the Appellant and rights of the Appellant, its customers and employees, passed an unreasoned and non speaking decision and communicated its intent to disclose the details of the said Reports by the impugned Order. Pertinently, the CPIO did not deal with any objection raised by the Appellant in its reply with respect to Section 11 Notice and hence, the decision arrived by the CPIO was issued in gross transgression of the principles of natural justice. He, further, submitted that while the Ld. FAA had relied upon the Hon'ble Supreme Court's Judgment in Transferred Case No.91 of 2015 Reserve Bank of India V. Jayantilal N. Mistry for disclosure of inspections report, it was apposite to mention that the Appellant amongst other bank had filed Writ Petition being Writ Petition No.1095 of 2019 before the Hon'ble Supreme Court of India inter alia challenging disclosure of vital information of the banks, including the inspection/ risk assessment reports. Thus, the issue pertaining to disclosure of inspection reports under the RTI Act was sub-judice before the Hon'ble Supreme Court of India in the said Writ Petition filed by several banks.

11. The appellants, YES Bank and Indian Bank referred the reply provided by CPIO and order passed by the FAA and submitted that the CPIO, RBI and FAA had violated the principles of natural justice, as they had not given any personal hearing to the Appellant Bank before passing their decisions in the matter. No reasons were given for not offering personal hearing in the first appeal. The counsel for the appellant prayed before the Commission that the FAA orders in the above mentioned cases should be set-aside for want of reasons. He further submitted that the information related to the bank as a whole should not be disclosed to the RTI applicant. The Counsel has further referred the Full Bench judgment of this Commission passed in file no. CIC/RBIND/A/2021/152460 & Ors. vide order dated 05.05.2022 wherein an identical issue of disclosure of Page 4 of 16 Inspection Report/Risk Assessment Report, has remanded to the CPIO for fresh adjudication by keeping in mind principles of natural justice.

12. The representative for the appellant bank i.e. Union Bank of India submitted that the Cooperation Bank is merged with the Union Bank of India. He further submitted that the CPIO, RBI vide notice dated 23.01.2020, rejected their objection and conveyed the intention to disclose the inspection report of the appellant bank for the FY 2015-16 after severing the information exempt from disclosure as per section 10 (1) of the Act. Aggrieved with the same, the bank filed a first appeal, but the FAA has also dismissed their appeal. He also submitted that their bank had filed a Miscellaneous Application vide M.A. No. 1046/2020 in the T.C. No. 91/2015 (RBI vs. Jayantilal N. Mistry) and vide order dated 28.04.2021, the Hon'ble Supreme Court has dismissed all the M.As on the ground of maintainability, with the liberty to pursue other remedies available. Subsequent to the above developments, on 25.06.2021, their bank has filed a Writ Petition before the Hon'ble Supreme Court, seeking quashing of the similar dismissal orders passed by the FAA of the RBI in respect of objections of the Bank under section 11 of the RTI Act and further prayer to direct the RBI, not to disclose without concurrence of Banks, any information/ data collected by RBI in course of inspections, audit or specific directions in exercise of its powers as regulator of Banks, including information about customers, management of the banks, business plans, trade secrets, risk ratings and other regulatory information and unpublished price sensitive information. the said Writ Petition has been registered and numbered as W. P. (C) No. 690/2021 and is pending adjudication before the Hon'ble Supreme Court and has since been tagged with other similar Writ Petitions filed by different Banks, for analogous hearing.

13. The representative for the appellant Bank i.e. Bank of Baroda submitted that providing the Inspection Reports made by the RBI post completing the inspection of commercial banks and NBFCs/HFCs might hamper the Bank's competitive position and would cause prejudice to Bank's commercial interest, hence, the disclosure thereof was exempted under section 8 (1) (d) of the RTI Act. The appellant bank further contended that Inspection Report contained third party/customer information, held by the bank in fiduciary capacity and disclosure of information to the RTI applicant might jeopardize the banker-customer relation and might amount to infringement of their fiduciary relation hence the same was exempted under section 8 (1) (e) & (j) of the RTI Act. Besides, the appellant bank vehemently argued that the CPIO of RBI while conveying his intention to disclosure the information, had failed to explain as to how the information sought would have served the larger public interest. In addition to the above, the appellant Bank relied upon the case: a writ petition (civil) No. 786 of 2021- Bank Page 5 of 16 of Baroda vs. Union of India & ORS before Hon'ble SC and made the following prayers:-

(a) "Issue a writ in the nature of writ, order of directions to CPIO and RBI not to disclose the confidential and sensitive information and strike down the said Impugned Actions taken by the CPIO, RBI as against the petitioner.
(b) Declare that information obtained by RBI in course of its inspections as well as in the course of its regulatory and functions related to banks and the financial institutions including information relating to customer/employees, information in relation to the management, business plan, trade secret and risk ratings of the petitioner bank, requirement & regulatory intervention any unpublished price sensitive information are exempted from disclosure under section 8 (1) of the RTI Act cannot be disclosed.
(c) Direct the respondent not to disclose any reports or any information whether in full or in part, contained in them which are exempted from disclosure under relevant provisions of section 8 of the RTI Act, and /or under any other law(s) for the time being in force.
(d) Direct the respondents to forthwith forbear from disclosure to applicants or otherwise information obtained by RBI in the course of it Inspections as well as in the course of its regulatory and related functions relating to banks and financial institutions."

It was informed by the appellant bank that aforesaid writ petition was pending before the Hon'ble Supreme court for considerations. The Supreme Court had issued notice in the matter and tagged the matter along with the concerned writ petitions. They further stated that since the matter was pending before the Hon'ble Supreme Court and other banks had preferred similar writ petitions (tagged), the matter was sub-judice and order if any passed by the Hon'ble CIC, there may be an irreparable injury to the appellant bank. Accordingly, they prayed to allow the present appeal of the bank and direct the CPIO, DBS, RBI not to part with the information as sought by the RTI applicant Shri Girish Mittal till disposal of the appeal.

14. The Counsel for the Axis Bank has referred the reply provided by CPIO and order passed by the FAA and submitted that the CPIO, RBI and FAA had violated the principles of natural justice, as they had not given any personal hearing to the Appellant Bank before passing their decisions in the matter. No reasons were given for not offering personal hearing in the first appeal. The counsel for the appellant prayed before the Commission that the FAA order dated 18.11.2019 should be set-aside for want of reasons.He further submitted that the Page 6 of 16 information sought by the RTI applicant was completely exempted as the information sought includes commercial information received in fiduciary capacity, disclosure of information sought is specifically prohibited under various legislations and is specifically exempted under Section 8 (1)(b), Section 8 (l) (d) and Section 8(1)(h) of the RTI Act. The disclosure of personal/ commercial information of the banks and its customers violated the right to privacy as guaranteed under the Right to life as enshrined under the Article 21 of the Constitution of India. Such disclosure would cause serious prejudice to the market value and reputation of the Appellant Bank and its customers. The Counsel has further referred the Full Bench judgment of this Hon'ble Commission passed in file no. CIC/RBIND/A/2021/152460& Ors. vide order dated 05.05.2022 wherein an identical issue of disclosure of Inspection Report, has remanded the matters to the CPIO for fresh adjudication by keeping in mind principles of natural justice. Moreover, considering the fact that several banks have filed inter alia Writ Petition No. 1159 of 2019& Ors tagged with it before the Hon'ble Supreme Court inter-alia impugning the disclosure of their Inspection Reports or parts thereof by the RBI under the RTI Act, this Hon'ble Commission has also held that any decision by the CPIO in respect of disclosure of Inspection Report would amount to pre-judging the issues pending the admitted Writ Petition (s) before the Hon'ble Supreme Court.

15. The representative of the Reserve Bank of India while presenting their case inter alia submitted that the applicants vide above RTI applications inter alia, sought, copy of Inspection Reports from year 2008-2021. They further submitted that the then CPIO issued the notice under Section 11(1) read with Section 11(2) of the Right to Information Act, 2005 (RTI Act) to the third party i.e. appellant banks informing that RBI was required to disclose the information sought by the above applicants, enabling appellant banks to make written submission as to whether the information sought by the applicants might be disclosed or not along with reasons for the same. After considering the response from Appellant Banks, the CPIO decided to disclose the detail of Inspection Reports from year 2008- 2021 to the applicants. He further submitted that the Hon'ble Supreme Court in RBI vs. Jayantilal N. Mistry & Ors (2016) 3 SCC 525 observed that :-

"RBI is clearly not in any fiduciary relationship with any bank. RBI ought to act with transparency and not hide information that might embarrass individual banks. It is duty bound to comply with the provisions of the RTI Act and disclose the information sought by the applicant.
The FAA observed that the interim order would apply only to those banks which are parties to the Petition, namely HDFC Bank Limited, Axis Bank Limited, Page 7 of 16 ICICI Bank, Yes Bank Limited and State Bank of India. The appellant banks i.e. Union Bank of India, Bank of Baroda etc were not a party in the aforementioned matters. Accordingly, it would not be possible for them to take advantage of the interim order dated 18.12.2019 passed by the Hon'ble Supreme Court.

16. The RTI applicants submitted that complete and correct information should be provided to them as per Jayantilal Mistry case. The information sought is not exempted under the provisions of the RTI Act. He stated that the appellant bank has wrongly claimed exemption in order to avoid disclosure of their information.

Decision:

17. The Commission, after hearing the submissions of the parties and after perusal of records, observes that the original applicants has sought detail of Inspection Reports made by Reserve Bank post completing the inspection, inter alia, pertaining to Union Bank of India i.e. appellant herein and 13 other banks (as mentioned in RTI Application) from the year as mentioned in the above RTI applications. The CPIO, Reserve Bank of India issued notices under Section 11(1) and 11(3) to the respecting banks mentioned above intending to disclose the information. Aggrieved by the decision of the CPIO, the said banks had filed first appeals with the First Appellate Authority. The FAA had also dismissed the first appeals of the banks summarily. Being aggrieved with the order of the FAA, banks had filed second appeals before this Commission.

18. The Commission observes that the RTI applicants had insisted for disclosure of information as per Jayantilal N. Mistry's case. The Appellant Banks contested that the information sought as a whole is exempted from disclosure under Section 8 (1) (b), 8(1)(d), 8(1)(e) 8 (1) (h) and 8(1) (j)of the RTI Act and that the CPIO/FAA has not passed any reasoned order settling their objections nor gave any opportunity of hearing to them.

19. The Commission further observes that the CPIO while issuing notice under Section 11 of the RTI Act has given the opportunity to the Banks to file their objections, if any, against disclosure of Inspection Reports/Audit Reports, etc. but has not found it necessary to give them an opportunity of hearing. While not doing so, the CPIO has not passed any reasoned order covering his deliberations on their objections, his understanding of law or jurisprudence in deciding specific objections, in favor of disclosure or redaction etc. Orders passed by the CPIO in all the cases are cryptic, almost identical without any reference to objections raised by the Banks which are definitely not identical. Similarly, the FAA instead of passing a speaking order has also given cryptic, almost identical orders to the appellant banks. The CPIO and the FAA are expected to apply their mind before issuing the order of intent of disclosing the information. Further, no opportunity Page 8 of 16 of personal hearing was given to the appellant nor speaking order have been passed by FAA for not giving opportunity of hearing or elaborating reasons for accepting /not accepting their objections in his decisions in these appeals. The Commission is of the view that every objection should be dealt and rejected/accepted with a reason and reasons for not giving opportunity of personal hearing should be well reasoned too in view of wider implications.

20. The Commission observes that rightful claims of the RTI applicants has to be adjudicated in the light of specific objections filed by the Institution, various judicial pronouncements of Hon'ble Supreme Court and High Courts providing guidance on such matters. Opportunity of hearing should generally be provided and orders passed by the CPIO and the FAA otherwise if denied or not given be reasoned, speaking and clear. In the present case, order by CPIO should enumerate the principles for disclosure or non-disclosure of inspection reports or part thereof which may include personal information, commercially sensitive information of clients or institution and hence specifically excluded disclosures under various Acts, etc.

21. In light of the above observations and considering all the facts and circumstances of the above mentioned cases, the Commission is of the view that contour of the arguments are identical as held in the Full Bench judgment of this Hon'ble Commission passed in file no. CIC/RBIND/A/2021/152460& Ors. vide order dated 05.05.2022. It has been observed that there are minor variations in the matters in hand when compared with the matters already decided by the Commission as above.

22. It has already been stated supra that detailed view in file nos. CIC/RBIND/A/2021/152460 & Ors. dated 05.05.2022 wherein issues of redaction, ratio of Jayantilal Mistry case and other related issues are discussed in detail. Perusal of the relevant paragraphs in Jayantilal Mistry judgment make it clear that the fundamental rights enshrined upon the citizens in form of right to information are not absolute and that the right to information may not draw precedence over right to privacy. Therefore, the Courts need to strike a balance between the rights as well as protections guaranteed to a citizen under Article 19 of the Constitution. Hon'ble Supreme Court of India has held that the disclosure of information relating to banks may be allowed taking into account the circumstances and nature of information sought for and not in a blanket manner. The Commission advised the CPIO to consider taking the relevant references from the said order while deciding the above mentioned cases.

23. Further, the Commission has already outlined the deficiency in the conduct of the CPIO/FAA while hearing such matters and hence is of the opinion that due care has to be taken by according opportunity of personal hearing and making Page 9 of 16 reasoned order with reference to the objections in the hands of the CPIO and later in the hands of FAA, if any appeal is preferred. Hence, the CPIO will be required to adjudicate such RTI applications in the light of the observations of the Commission afresh. The Commission also expects that the CPIO will take view on various objections filed by the Appellant and submissions made by applicant to reach the decision in favor or against on case to case basis. He has to factor the observation of Hon'ble Supreme Court in Jayantilal Mistry case, Commission's judgment dated 05.05.2022 and other relevant judgments, some of which have been referred in this order as well. Hence, with these observations the order passed by the CPIO and FAA in these matters is set aside and the case is being remanded to the CPIO for adjudication afresh in line with the Commission full bench decision passed in file nos. CIC/RBIND/A/2021/152460 & Ors. dated 05.05.2022. In case, the appellant/applicant is aggrieved with the order of the CPIO, they are at the liberty to file first appeal before the First Appellate Authority and afterwards second appeal before the Commission.

24. With the above observations, all the above appeals are disposed of.

25. Copy of the decision be provided free of cost to the parties.




                                                             नीरज कु मार गु ा)
                                         Neeraj Kumar Gupta (नीरज           ा
                                                                 सूचना आयु )
                                       Information Commissioner (सू

                                                          दनांक / Date : 03.08.2022
Authenticated true copy
(अिभ मािणत स यािपत  ित)


S. C. Sharma (एस. सी. शमा),
Dy. Registrar (उप-पंजीयक),
(011-26105682)




                                                                         Page 10 of 16
 Addresses of the parties:

1.    CPIO
      Reserve Bank of India
      Department of Supervision, Centre-1
      World Trade Centre, Cuffe Parade, Colaba
      Mumbai-400005

2.    Mr. Dinesh Kumar Sharma (Original Appellant)

3.    Mr. Shailesh Gandhi (Original Appellant)

4.    Mr. Sumitender Das (Original Appellant)

5.    Mr. Jaidev S Kalyani (Original Appellant)

6.    Ms. Amita Mittal (Original Appellant)

7.    Mr. Advait Rao Palepu (Original Appellant)

8.    Mr. Jitender Gupta

9.    Ms. Samita Sandhane

10.   Mr. A Rajendran

11.   Mr. Dinesh Harchandani

12.   Mr. Pradeep Kumar C Nair

13.   Mr. Navin Trivedi

14.   Mr. Sunil Kumar Jha

15.   Mr. CP Srivastava

16.   Mr. SK Patnaik

17.   Mr. Bipin Chandra Khanna

18.   Mr. Rudrapriyo Ray




                                                     Page 11 of 16
                                                     Annexure (A)
Sr. No.   File No.                                              RTI                                     CPIO          FAO
1         CIC/RBIND/A/2021/130761                            08-03-2021                               08-04-2021   12-07-2021
                                                                                                        -:DO:-       -:DO:-




2         CIC/RBIND/A/2021/616628                             11-11-2019                              09-12-2019   12-01-2021
                                    1. Please provide me a CD containing the annual inspection          -:DO:-       -:DO:-

report of State Bank of India for the year (a) 2012 (b) 2013

(c) 2014 (d) 2015 (e) 2016 (f) 2017 (g) 2018

2. Please provide me a CD containing the annual inspection report of UCO Bank for the year (a) 2012 (b) 2013 (c) 2014

(d) 2015 (e) 2016 (f) 2017 (g) 2018 Page 12 of 16 3 CIC/RBIND/A/2018/170550 03-05-2018 01-06-2018 31-08-2018

-:DO:- -:DO:-

4 CIC/RBIND/A/2019/149848 06-05-2019 27-05-2019 18-07-2019 & -:DO:-

12-06-2019
-:DO:-
Page 13 of 16

5 CIC/RBIND/A/2020/110642 05-07-2019 16-10-2019 25-11-2021

-:DO:- -:DO:-

6 CIC/RBIND/A/2020/108661 05-07-2019 16-10-2019 19-11-2021

-:DO:- -:DO:- -:DO:-

7 CIC/RBIND/A/2021/631037 02-05-2019 25-06-2019 21-06-2021

-:DO:- -:DO:-

8 CIC/RBIND/A/2021/101496 02-05-2019 25-06-2019 16-03-2020

-:DO:- -:DO:- -:DO:-

9 CIC/RBIND/A/2021/600195 02-05-2019 25-06-2019 16-03-2021

-:DO:- -:DO:- -:DO:-

Page 14 of 16

10 CIC/RBIND/A/2021/614140 26-04-2019 03-12-2019 19-01-2021

-:DO:- -:DO:-

11 CIC/RBIND/A/2021/117309 14-08-2019 23-01-2020 16-03-2020

-:DO:- -:DO:-

12 CIC/RBIND/A/2021/602631 14-08-2019 06-09-2019 16-03-2020

-:DO:- -:DO:- -:DO:-

Page 15 of 16

13 CIC/RBIND/A/2021/616093 26-04-2019 23-01-2020 04-01-2021

-:DO:- -:DO:-

14 CIC/RBIND/A/2020/105506 05-07-2019 24-09-2019 18-11-2019

-:DO:- -:DO:-

Page 16 of 16